The current administration has challenged businesses across the country to help create new jobs.  Environmental Services & Solutions Corporation (Essco Safety Check), a Redmond, WA based company steps up to the government’s challenge by:

• Proposing the creation of thousands of jobs. 
• Helping to stimulate business; especially small businesses impacted by the Consumer Product Safety Improvement Act (CPSIA).

The CPSIA (Consumer Product Safety Improvement Act) is a law that regulates the amount of lead and other harmful toxicants in children’s products.  There are approximately 700,000[1] manufacturers, importers, wholesalers and retailers that are impacted by this current legislation; approximately 40%[2]of these businesses have 0-4 employees working for them.

Currently, XRF testing is not a government approved testing method.  Current approved testing methods are destructive in nature; which means the tested product must be destroyed during the testing procedure.  This method of testing is very costly and the test results could take weeks to obtain.  In addition, products can only be tested by a select group of government approved testing laboratories worldwide.

XRF testing equipment is completely portable; it can be easily transported to the testing site.  Testing using XRF is non-destructive, low-cost, fast and an accurate way to determine if elements (including those regulated by the CPSIA) are present or not present in virtually anything.  If XRF technology becomes a government approved screening process, it is estimated that thousands of jobs could be created nationally.  These jobs include certified consumer product inspectors, support staff and office positions.

A direct result of XRF screening is to prevent potentially harmful products from reaching the retailer’s shelves and eventually the homes of consumers. 

By utilizing XRF analyzers to screen consumer products, businesses could save money on government mandated testing expenses and be able to get products to market faster.  For example, traditional testing is destructive in nature, very expensive and time consuming; it costs, on average, $100 per test (each product may need 5 tests) and can take weeks for results.  XRF testing costs on average $2 to $7 per test and usually provides results within 48-hours.

Hypothesis:  If XRF Analyzers and technology are approved for screening heavy metals in children’s products and with a conservative estimate of 5 million products that need to be tested with an average of 5 tests per item, over $3.7[3] billion dollars can be saved.  However, research has suggested that there are literally tens of millions of products that are potentially impacted by the CPSIA regulation and, with that number in mind, there could be savings in the tens of billions of dollars for business all while creating thousands of jobs.

ESSCO-Safety Check proposes that by using XRF technology:
• Thousands of jobs can be created.
• Businesses will be in compliance with CPSIA regulations.
• Mandatory testing expenses are reduced for business.
• Products get to market faster.

It’s a win-win situation for consumers, the environment and business.
www.essco-safetycheck.com

[1] www.naics.com North American Industrial Classification System
[2] www.census.gov  U.S. Census Bureau
[3] http://handmadetoyalliance.blogspot.com/2010/02/allowing-xrf-testing-for-cpsia.html Handmade Toy Alliance Blog – Cross Post from Essco Safety Check

The CPSIA was written in 2008 to ensure that children’s products don’t contain harmful amounts of certain elements, like lead and cadmium.  All children’s products must eventually be certified by an accredited 3rd party laboratory who utilizes specific testing methods.  With these laboratory results a company can create the required general certificate of conformity (GCC).

There is also a stay of enforcement with the CPSIA until 2/10/11 for the GCC on all children’s products other than those that are painted, children’s jewelry, cribs or pacifiers.  Additionally, there is regulation in total content of lead and regulation in soluble content for eight elements (including lead), this method (soluble) ASTM F-963 is currently voluntary.  There is also regulation for the amount of certain phthalates, a chemical added to plastics to make them softer.

All current approved testing methods are destructive, they are very costly, can take extensive periods of time to get results.  This testingcan only done by a select group of laboratories (only 227 worldwide and 60 within the United States, many of these labs have one parent company). 

While researching this article, I attempted to find an economic impact analysis that was performed for CPSIA, but was unable to find one.  I even contacted a state representative with Washington State, in April 2008, four months prior to the federal CPSIA regulation, Washington State passed the Children’s Product Safety Act, but apparently no impact study was done either.

How does one figure out the economics behind this piece of legislation? 

I thought to try and simplify things and try to figure out how many businesses would be impacted, what size of business they are and ultimately how products that would be affected.  I will compare an approximate cost of traditional testing methods, to a technology that is mobile and non-destructive (X-Ray Fluorescence).  And I will show how many jobs could be potentially created. 

Number of businesses potentially affected by the CPSIA

Businesses that are potentially affected by the CPSIA include; Manufacturers, importers, retailers, charities and re-sellers who make, distribute in commerce, children’s products, those designed and marketed to children 12 and under.

I found two main sources for this data, the US Census and the North American Industry Classification System (NAICS).  The US Census numbers were from 2006 and the numbers from the NAICS are from 2009.

Here is data from the North American Industy Classification System (NAICS)  their data was used to calculate the number of potentail businesses affected by the CPSIA.

Total number of manufacturers potentially affected by the CPSIA in the United States 52,544***
Total number of wholesalers potentially affected by the CPSIA in the United States 125,624***
Total number of retailers potentially affected by the CPSIA in the United States 511,240***
Total number of businesses potentially affected by the CPSIA according to the NAICS 689,408***

The US Census provided data on the size of the businesses affected and is broken down by percentage.  My use and definition of small business is based on <500 employees, however, I include data on 0-4 employees and <20, this data is based only on the businesses potentially affected by the CPSIA.

Total Manufacturers potentially affected have 0-4 employees 46.3%, <20 employees 78.7% and <500 employees 97.4%*** (these are cumulative totals)
Total Wholesalers potentially affected have 0-4 employees 54.1%, <20 employees 79.7% and <500 employees 94.8%*** (these are cumulative totals)
Total Retailers potentially affected have 0-4 employees 37.9%, <20 employees 56.9% and < 500 employees 65.7%*** (these are cumulative totals)
Average for all businesses potentially affected by the CPSIA have 0-4 employees 40.2%, <20 employees 60.8% and <500 employees 70.9%*** (these are cumulative totals)

What does all of this mean?  More small businesses are going to be affected by this regulation than large businesses.  40% of all businesses potentially affected by the CPSIA are very small with only 0-4 employees. 61% of all businesses potentially affected by the CPSIA have less than 20 employees.  All businesses classified as small businesses, less than 500 employees, 71% of them potentially will be affected by the CPSIA.

Number of products potentially needing testing

Attempting to figure out the amount of SKUs or total products potentially affected was an even larger task than trying to figure out the number of businesses potentially affected.  There is no single source of data about the number of products manufactured or sold, so I took a slightly different approach.  I researched a few key consumer websites and contacted a few experts to make my assumptions.

Yes, I said assumptions.  The problem with figuring out some specifics is that I’m guessing on a few key points.  Here we go!

I first visited ETSY.com.  ETSY.com is a website that sells handmade consumer products, you know, made by your friends and sold online.  When I looked on their site earlier this week, they had over 280,000 children’s products listed.

I decided to go to two other major consumer product retail sales websites, Buy.com and Amazon.com.  At Buy.com when I tallied all the potential products that could be affected by the CPSIA I found over 66,000 different products.  On Amazon.com the amount was much more.  I will add one caveat, at amazon.com they did not separate jewelry into a product category “children’s jewelry” so I used the total of all jewelry in my tally.  With all jewelry listed and all other products I found that could be potentially affected by the CPSIA, the total was almost 1.18 million products on Amazon.com.  Without the jewelry the total was over 150,000 products.

In a conversation I had with a regulatory agency employee in the State of Washington, she suggested that the total number of potential products on the market is in the tens of millions.

Based on these numbers and suggestions, I’m going to split the middle and suggest that there are five million different products on the market that could be impacted by the CPSIA.

The Cost Breakdown

First we need to look at the traditional testing methods.  I’m only going to look for three things, amount of lead, amount of cadmium and phthalate testing (traditionally this is tested using a Gas Chromatography machine).  For this analysis, disregard all other potential costs.

Traditional ICP-MS testing for heavy metals can easily be hundreds of dollars per test, per color, per substrate.  I have been quoted ranges from $75 to $300 per test for heavy metal testing; phthalate testing has been a bit lower from $75 to $150.  For this comparison, I’m going to use the low end of $75 per test.

I am also going to assume that every item needs to be tested a total of five times.  Every product is a little be different, they’re made with different colors, different substrates and materials.  Take an old childhood favorite Rubik’s Cube.  It has six different colors and is made of one substrate (black plastic), that item would require a minimum of seven tests.  As I said, I’m going to use a five test average.

If there are five million items and each has to be tested five times, that is a total of twenty-five million tests.  Considering we are looking for three things (lead, cadmium and phthalates at $75 per test) the total for traditional testing methods would be $5.625 billion.

If all the accredited laboratories split this testing evenly, that would be approximately $25 million per lab worldwide.

Other testing method

There is a technology that is mobile and non-destructive that can simultaneously look for lead, cadmium and PVC in one simple push of the button.  Unfortunately, it is not the approved testing method for the CPSIA.

This technology is called X-Ray Fluorescence (XRF) and is readily available to use for consumer product testing.  It is the approved testing source for HUD Lead inspections, and is used by the EPA, FDA and CPSC.

Data that I have collected from over 8000 test results using XRF analyzers shows that of all consumer products tested only 16.3% are found with any amount of lead, 4.3% are found with any amount cadmium and 11.1% are identified to be made of PVC.  In total only 31.7% of all consumer products I have tested using XRF analyzers have been found with lead, cadmium or PVC, yet all products are required to be tested destructively.

I used these percentages to help figure out the comparable numbers.

Comparison

If all products are tested by traditional testing methods using ICP-MS and GC machines the cost for testing for lead, cadmium and PVC would be $5.625 billion.  However, if you were to use XRF analyzers to screen all these products, at a cost average of $5.00 per test the total cost would be $125 million. 

At this point, all items that tested positive for lead, cadmium or PVC should be further tested by the traditional testing methods.  Using the percentage of items found with lead, cadmium or PVC (31.7%) traditional testing methods would cost $1.784 billion.  If you add up the XRF screening and then the re-testing by traditional testing methods, the costs would be approximately $1.9 billion. 

That would be a cost savings of $3.7 billion or 66.1% for consumer product testing for the CPSIA.

That is a tremendous amount of money that these businesses can put back to work in our economy, hiring people, investing, building business all while keeping compliant with the regulations.

Number of jobs created

I’m going to specifically look at this as the formation of XRF Certified Consumer Product Inspectors.  If a total of twenty-five million tests need to be done annually, and each inspector can do two hundred tests per day, two hundred and fifty days per year, that could create five hundred jobs.  That is not including managers and office staff to handle additional work.  Overall, I would suspect that close to one thousand jobs could be created, but that is only based on five million products that need to be tested.

What if that total number is closer to twenty million?  That would potentially be upwards of four thousand jobs and a potential economic impact of close to $15 billion going back in to the pockets of businesses of which almost 71% are considered small businesses.

Conclusion

What I’m suggesting is a common sense approach to testing and the certification that consumer products meet the regulations of the CPSIA.  If XRF testing is approved to simply screen products for certain heavy metals and PVC, and only those found to contain these elements or chemicals would be further tested, there can be a huge positive economic impact for small businesses, as well as the creation of jobs.

***These figures were calculated from two sources, the US Census and the NAICS.

Recently a report from the Iown Department of Public Health noted that there has been an increase in childhood lead poisoning do to home remodeling.

XRF Analyzers are non-destructive, handheld, scientific instruments for identification of elements, essentially a handheld mass spectrometer.  They are an approved source to determine if lead-based paint is present in a HUD property (government owned).

EPA Requirements 

Common renovation activities like sanding, cutting, and demolition can create hazardous lead dust and chips by disturbing lead-based paint, which can be harmful to adults and children.

To protect against this risk, on April 22, 2008, EPA issued a rule requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning. Under the rule, beginning in April 2010, contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination.

Until that time, EPA recommends that anyone performing renovation, repair, and painting projects that disturb lead-based paint in pre-1978 homes, child care facilities and schools follow lead-safe work practices.

All contractors should follow these three simple procedures:

Contain the work area.
Minimize dust.
Clean up thoroughly.

The RRP Rule is simply designed to assure that workers and homeowners are protected from the harmful effects of lead.  There is unfortunately one major flaw with this rule, Clearance! 

Clearance is done at the end of the job to make certain that the work site has been cleaned up properly.  A dust wipe is performed and this wipe is compared against a picture on a laminated card.  How is this testing for lead? 

What I think

In my opinion, when XRF Analyzers are combined with an appropriate data collection and analysis platform they can provide sufficient evidence and quantification for lead.  This mobile, non-destructive testing platform, that is capable of identify as little as 10 parts per million (PPM) of lead.  With a specific set of testing methods and our pending new quantification system, XRF can positively impact the EPA RRP Rule.

X-Ray Fluorescence can create jobs, help contractors comply with regulation, help homeowners be safe from lead and other potential harmful toxicants. Contractors can move from site to site (job to job) quicker.  Their testing costs can be lowered and testing information instant.  This all can produce economic and social benefits.

I believe there are many other opportunities for X-Ray Fluorescence to positively impact society, create jobs and improve lives.

Some ideas are based on prevention and reducing exposure to heavy metals.  This can be done in several ways, blood lead prevention (specifically for children 6 and under), environmental exposure assessments, consumer product testing, inspections at ports of call and many other industries and market segments.

By utilizing a combination of advanced X-Ray Fluorescence (XRF) analyzers, Lead Care II machines (mobile blood lead screening) and sophisticated analytical software, we can quickly obtain accurate and reliable information about the presence of environmental contaminants.  Specifically lead in blood and a variety of heavy metals in virtually any object including; lead, cadmium, arsenic, mercury and may other heavy metals. 

If technology is used appropriately, knowledge of environmental concerns is easy to obtain, mobile, reliable, efficient, cost effective and scientifically accurate.  I believe that thousands of jobs can be created; children will be less exposed to heavy metals, which have important health, intellectual and economic benefits.  Businesses can reduce expenses while preventing harm, complying with regulation and have products get to market faster, cheaper and more efficiently. 

Here is one example:

Childhood lead poisoning prevention (blood lead screening and environmental assessments), is not a major problem, but costly in healthcare, social and economic expenses.  In 2006, according to the CDC there were 23,485,435 children in the U.S. 72 months or younger, yet in 2006 only 3,262,866 children or were screened for lead in their blood.  Lead poisoning has steadily been declining in the US, however, in 2006 39,526 were confirmed to have elevated blood lead levels (EBLL) while over 20 million children under age 6 were not screened, many living in high priority areas.  In a report, “Environmental Pollutants and Disease in American Children…Costs for Lead Poisoning” by Philip J. Landrigan July 2002, total annual costs are estimated to be $43.4 billion for lead poisoning.  These costs include actual costs for medical care and economic forecasting associated with lower IQ scores and thus lower wages and reduced lifetime earning power.

At the very least medical expenses for the children found with EBLLs can easily be estimated in the one to two billion dollar range annually.  I believe we can identify and reduce childhood lead poisoning by directly screening children ages 1, 3 and 6 all across the country for lead (using the mobile Lead Care II machines).  This will do several things; first it should create two to four thousand jobs across the United States.  Second, if a child is found with an EBLL a further investigation would be prompted and an investigator would enter the child’s home environment and provide a full assessment (using technology, specifically XRF), provide education, recommendations and follow-up monitoring and testing. 

The total costs estimated to provide all of these testing services are around half a billion dollars for all children aged 1, 3 and 6 each year.  The potential immediate gains are, thousands of people employed all across the country, all children get screened for blood lead levels, and those found with EBLLs will immediately receive further assistance, while billions of dollars are saved.   Long term benefits include reduced strain on healthcare system, higher wages and better economic status for those directly affected as well as those employed.  You could expect to find higher IQ scores and thus a rise in math and science test scores (over time) as well as reduced rates of criminal activity.

New industries can easily rise up from this project.  Imagine this, a child is found with an EBLL and an investigator goes to the home, tests are preformed on the toys, ceramics, jewelry, soil, housing and other items and specific items in the child’s environment have been identified to contain lead using XRF Analyzers.  The parent wants these items removed from their home, but typically would send it to the dump, a potential environmental hazard.  Here is an opportunity to create an entire new industry of clean recycling to get the “lead” out and reuse the material.

Here is a second example:

What about the Consumer Product Safety Improvement Act (CPSIA)?  X-Ray Fluorescence (XRF) Analyzers are the preferred source for the HUD to detect lead in a government owned properties, why not use them for consumer product testing?  As a business owner specifically related to this field, I believe that thousands of jobs can be created in every community around this nation with the use of XRF analyzers.  If something isn’t done, the CPSIA is going to affect small businesses tremendously (a stay was recently issue (December 2009) which extended the date on specific certification and testing requreiements for children’s products to February 10th, 2011). 

When you compare XRF technology there are three main points to look at; Accuracy, Mobility and Cost.  One issue raised by the CPSC for XRF is the accuracy, more to the point, quantification of XRF.  My company is specifically working on this issue.   We are working on software solutions to the potential problems associated with XRF and hope to present this data to the CPSC, EPA, HUD and other agencies that are interested in our solutions. 

Regardless, with lead, we have never had a false positive.  If regulation calls for testing and our analyzers do not find lead while testing, I can reasonably say “No lead is present.”  If lead is found, and you want to question the quantification, fine, have traditional testing done.  But if no lead is found, why make a business pay for expensive destructive testing? 

XRF Analyzers are mobile, non-destructive and perfect for identifying heavy metals.   Compare this to the fixed site laboratory and the mobility offers opportunities in job expansion, while reducing expenses and increasing time that products can get to market.

When we compare costs of XRF (new technology) to traditional testing methods, specifically with comparison to the CPSIA we see a huge difference.  Traditional testing costs can range from $75 to $300 per color, per substrate and take weeks to get results.  XRF offers a low cost, immediate results platform where costs range from $2 to $7 per test, per color, per substrate. 

Also, both XRF and Lead Care II have almost instantaneous results (with seconds using XRF and minutes using Lead Care II)

Here are a few opportunities to create jobs and improve the lives of people and children all across this country.  To improve the health and wellbeing of people, reduce healthcare expenses, reduce business expenses and help business comply with federal regulations while putting thousands of people to work all across the country.

If you would like to contact me, please visit www.essco-safetycheck.com

We are Environmental Services & Solutions Corporation - Safety Check and we use technology to help people and businesses “know what is in their environment” these are just a few ideas of how technology can help to improve lives and create jobs.

Currently, we (Essco) serve four segments of the market; Consumer, Business and Industrial and Government, but XRF can be utilized in many different segments of each market.

The consumer may have a need or desire to have their home, property, consumer products inspected for heavy metals.  Moms and dads who are environmentally conscious and concerned about their environment, people or families that have family members with compromised immune systems, new home buyers or home remodelers.

Businesses who are required or desire to ensure that their consumer products do not contain harmful heavy metals, such as lead, as required by the Consumer Product Safety Improvement Act (CPSIA) or ROHS/WEEE Compliance.  Manufactures may wish raw materials tested or facilities to ensure worker safety.

Industries who need knowledge of material makeup can utilize XRF Analyzers in a variety of different segments; Geological (Mining, Exploration, Contaminated Sites, Archeological), area and product mapping, metal and alloy testing, preventative maintenance and data analysis.

XRF is the preferred source by Housing & Urban Development (HUD) to perform HUD Lead Inspections and Risk Assessments.

Essentially, XRF technology can provide information, fast, in-expensively, efficiently and accurately about the elemental makeup of anything but air. 

It is used in many different segments of the market and combined with data collection and analysis, XRF analyzers can help to improve lives and create jobs.

What other technologies exist that can help to reduce expenses for businesses, help businesses comply with regulation, keep children and people safe from potential toxic exposures, thus improving lives, creating jobs and new industries?

Know what is in your environment!